Interesting piece on Law 360 here by Howard Weissman all about mitigating FCPA risks with tailor made compliance.
In this piece Howard talks about how multinational companies should take a pragmatic approach to Foreign Corrupt Practices Act compliance by being aware of key risk areas - such as inappropriate gift-giving, liability for third-party actions, and countries with recurring corruption issues — and implementing custom-designed procedures that evolve with their operations.
I especially want to draw your attention to his point on how “90% of FCPA enforcement actions against companies involve a third party providing some service to a company.” This goes to show how essential it is to implement a robust procedure around third parties and actually made me think of our Digital Twin proposition here at A&M.
Through Digital Twin, we’re helping companies operationalise their compliance program using data analytics to measurably demonstrate effectiveness in line with regulator’s expectations.
A&M Digital Twin addresses the legal and compliance risks in client’s financial data bringing better transparency into:
- Anti-bribery and anti-corruption
- Sanctions and trade compliance
- Fraud, waste and abuse
- Third party risks and improper payments
- Revenue recognition and customer/distributor risks
- Conflicts of interests and segregation of duties
- Employee travel and entertainment
To find out more on Digital Twin contact Vincent Walden
90% of FCPA enforcement actions against companies involve a third party providing some service to a company.